United States v. Morgan

CONNALLY, Chief Judge.

This is an action by the Government seeking to reduce to judgment assessed tax claims against the Defendant. All of the facts are the subject of a stipulation. The only question is one of law, i. e., whether the action was timely filed. This in turn depends upon the construction to be given to certain waivers of the statute of limitations, all embodied in a series of offers in compromise made by the Defendant as hereinafter set out.

The assessments were made for the calendar years and in the amounts as follows:

The pertinent limitation statute is Section 6502 of the…